The True Value of Organic - CCOF

AdvocacyCCOF’s Policy Director has beenbusy drafting comments onproposed regulations brought forth bynumerous federal and state agencies.On behalf of our members, CCOFremains active in the regulatory processesaffecting organic production andprocessing. Below is a summary ofCCOF’s recent feedback and commentaryon some of the most pressingcurrent issues.Defending Organic DairyProducers’ Right to LabelCCOF provided comments to theKansas Agriculture Departmentregarding a proposal to dictate labelsfor dairy contents. By making it illegalto have a label that said “containsno rBST” or “contains no Rbgh”, theKansas proposal will:• Prohibit labels that communicateproduction practices requiredby law under the Organic FoodProduction Act of 1990;• Prohibit labels that are eitherexpressly permitted ina number of states or notprohibited in other states;• Dictate not only the words butalso the form, size, location andeven color of language that mustbe used on dairy product labels.The regulation stifles free speechby unduly regulating the languageprocessors may use on their packages,restricts the flow of products in interstatecommerce and interferes with andis preempted by longstanding federalorganic law. This recent proposal is acontinuation of the legal battle thatbegan in Pennsylvania and Ohio andhas the potential to go beyond dairylabeling to all organic products. Otherstates such as Indiana, Missouri andUtah may follow and CCOF willcontinue to remain active in the fightto prevent these potential restrictionsacross the country on organic labeling.New Amendment toPasture RulingOn October 24, 2008, the USDAproposed a revised standard tothe livestock and related provisions ofthe National Organic Program’s (NOP)organic regulations. The new amendmentincludes changes that will affectall organic livestock producers, includingdairy producers and organic beefoperations, especially regarding accessto pasture. CCOF has analyzed the newruling and has provided comments tothe NOP. CCOF clients helped us incrafting our response to these proposedchanges. CCOF’s comments as well asthe full text of the proposed regulations,including background and discussion,can be found at www.ccof.org/nop.php.Commenting at theNOSB MeetingCCOF Executive Director PeggyMiars, Policy Director ClaudiaReid and Grower/Livestock CertificationSupervisor Robin Allan representedCCOF members at the November meetingof the National Organic StandardsBoard (NOSB). During the meeting,CCOF commented on a majority ofthe agenda items including the 100%organic labeling rule, inert ingredients,organic pet food regulations andpetitioned materials. View a full reporton the NOSB meeting on the CCOFwebsite (http://www.ccof.org/nop.php).Petitioning for Protection-Field Trials and the Risk ofGE ContaminationThe USDA Animal Plant HealthInspection Service (APHIS) acceptedcomments on a proposal to drasticallychange its sanctions on the interstatemovement and release of geneticallyengineered crops and animalsthrough experimental field trials. Sincethese organisms are prohibited in anorganic system, CCOF took an activerole in petitioning APHIS to ensure andmaintain a level of confidence thatthe permitted field trials will not harmneighboring cropping systems or putorganic farmers or consumers at risk ofcontamination. CCOF opposed provisionssuch as “conditional exemptions,”“non regulated status” and Low-LevelPresence (LLP) which would decreaseexisting constraints limiting the releaseand movement of genetically engineeredproducts during field trials.Genetically Engineered(GE) Livestock—OpposingNew RegulationsThe Food and Drug Administration(FDA) sought comments about anew genetically engineered animalregulation, which classifies GE animalsinto four categories:• animals that produce human oranimal pharmaceuticals, oftenreferred to as biopharm animals• animals that serve as models forhuman diseases• animals that produce high-valueindustrial or consumer products,such as fibers• food use animals with new traitssuch as improved nutrition, fastergrowth or lower emission levels ofenvironmentally harmful substances,such as phosphate in manure.CCOF’s comments focused on thethird and fourth categories and areoutlined below:CCOF opposes the use of geneticengineering in animals to either producehigher value consumer productsthan are produced conventionally, orto create food animals with new traitssuch as improved nutrition, fastergrowth or lower emission levels ofenvironmentally harmful substances.22 CCOF Certified Organic Magazine—Winter 2009